Lockhart Power Company Transmission Planning Strawman

This document is the strawman proposal describing the transmission planning process to be used by Lockhart Power Company in compliance with Order No. 890. 

Lockhart Power Company intends to execute transmission planning in accordance with the nine principles which the Federal Energy Regulatory Commission (FERC) has expressed are needed in order to strengthen the pro forma Open Access Transmission Tariff (OATT) against the possibility of undue discrimination, make discrimination easier to detect and facilitate the Commission in its enforcement efforts.  The nine principles are: coordination, openness, transparency, information exchange, comparability, dispute resolution, regional coordination, economic planning studies, and cost allocation.  Each principle is addressed below.

Coordination and Openness

Lockhart Power Company will provide a public forum for customers receiving tariff service to serve load (LSE), transmission and interconnection customers, and neighboring utility systems to meet whenever we propose expansion planning in the region where our transmission division is located.  Energy or marketing affiliates of Lockhart Power Company may not attend this public forum unless there is an additional or potential customer present at the meeting.  It is expected that non-public utility recipients of the transmission planning information will abide by the Standards of Conduct reciprocity condition.  Lockhart Power Company provides further coordination and openness with respect to its transmission planning data by participating at the Regional Reliability Organization (RRO) planning level for the region in which it is located.

Transparency

Expansion planning criteria, data assumptions, study methodology and processes are available to the public forum through written documentation.  Lockhart Power Company will use a regional case model as a starting point for the accurate modeling of the generation resources and transmission system, updated with operating conditions, load, and necessary data to model the expected period.  Contingency analysis will occur after the model has been updated with the relevant participants' specific data.  All of the transmission, generation and load data used by Lockhart Power Company will be provided by regional transmission and generation representatives, as well as those additional entities referenced in the Coordination and Openness section of this document. 

Information Exchange

Information will be exchanged with interested parties through the open forum meeting, which will provide the interested parties the ability to submit data to Lockhart Power Company in the proper case study format.  All customer service requests will be treated on a comparable basis to other customers in a similar situation.

The information exchanged on forecasted customer data will be used between Lockhart Power Company and its OATT Network and Point-to-Point transmission customers.  Any good faith projections of service needs submitted by a Point-to-Point customer, even though a transmission reservation has not yet occurred, should be submitted for the study process.  Transmission customers may provide proposed demand response resources and peak demand impacts if desired for study.

Comparability

All OATT service customers’ service requests, both transmission and generation, will be treated comparably with other similar customers in a similar situation in the Lockhart Power Company transmission planning process.    

Dispute Resolution

Lockhart Power Company will provide a dispute resolution process as part of its transmission planning process to be used whenever a retail native load customer and a similarly-situated transmission customer dispute the procedural or comparability of the planning issues. 

Regional Coordination

Lockhart Power Company will comply with the Regional Coordination principle through continuing planning efforts with the only interconnected regional utility (Duke Energy).  Lockhart Power Company will share data with the interconnected regional utility to ensure they are simultaneously feasible, follow the guidelines in the regional study process to provide consistent assumptions and data, and assist in addressing the issues resulting from the study process.

Economic Planning Studies and Cost Allocation

Recognizing that planning involves the reliability of the Lockhart Power Company system and taking into account economic considerations, Lockhart Power Company will consider proposed upgrades or other investments that can enhance reliability and/or reduce the overall cost of serving its customers' needs.